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relations with non-federal entities - United States Department of ...

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PRACTICAL APPLICATION EXAMPLES:Hints: Get as many facts as possible, both for the immediate questions and for any possiblefuture questions that may arise. Keep your analysis narrowly focused on the separate parts <strong>of</strong>the overall questions, as it is very easy in this area to start mixing up the law and the facts.Whether DoD may provide support in the form <strong>of</strong> speakers is different from whether DoDpersonnel may attend an event, which is different from whether they may accept a gift <strong>of</strong>attendance, and if so, in their <strong>of</strong>ficial or personal capacity. Also, just because a <strong>non</strong>-Federalentity asks for a widely attended gathering determination does not mean that such adetermination is relevant to what the <strong>non</strong>-Federal entity really wants or what our personnelneed.Training Conference: The Armed Forces Communications Association is sponsoring a 3-day conference on Bandwidth in San Diego, California. It invited your Commander (from abase in Virginia) to speak on the morning <strong>of</strong> the 2 nd day. He really wants to go, as theCommand is vitally interested in bandwidth. He asks for an ethics opinion as to whether hemay accept. The Association also invited him to attend a general reception sponsored by aDoD contractor on the first night <strong>of</strong> the conference.Do you have enough information? No.What information do you need? You need information to determine whether the event couldbe a training conference or whether you could provide support under JER 3-211. Also, itwouldn't hurt to gather data for a determination about a widely attended gathering just in casegifts <strong>of</strong> attendance are involved.First, go to the AFCA website and find the conference. If you don't find everything you needthere, call the conference point <strong>of</strong> contact. You learn that the agenda is a full three days <strong>of</strong>substantive topics, both individual speakers and panels. There is also a luncheon speaker onthe second day. There is a dinner the second night which is strictly a social event formembers <strong>of</strong> the Association. The website mentions the reception the night before and has alink to the DoD contractor's website for additional information. There you find that everyoneattending the conference is invited, and it will be held immediately at the end <strong>of</strong> the lastlecture, 5:00 PM, and will be only 2 hours. The attendance fee for the conference is $599 aday for DoD personnel and members <strong>of</strong> the Association, and $699 for all others. You alsocalculate that 80% <strong>of</strong> the speakers seem to be from various DoD organizations.Oh, the Commander just called – the Association is waiving the attendance fee for him forthe entire 3 days and throwing in an extra free attendance. He is also a member <strong>of</strong> theAssociation and would like to attend the dinner the 2 nd night. It costs $35 extra, and theAssociation did not include that in the waiver.Are you still missing any information? Yes. What? Are DoD personnel going to attend, andif so, how many? How can you find out? First, did the website have a section on who shouldattend? Does it mention DoD personnel? Call the Association and ask them if they held asimilar conference previously, and do they have statistical breakdown <strong>of</strong> attendees? Most do,especially when they have several ticket prices. If not, do they have an expectation? Again,Relations <strong>with</strong> Non-Federal Entities10th Ethics Counselor's Course37

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